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IRS priority guidance plan 2018-2019—exempt organization projects

IRS priority guidance plan—exempt organization projects

The U.S. Treasury Department and IRS on November 8, 2018, released the 2018-2019 priority guidance plan.


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The 2018-2019 priority guidance plan [PDF 123 KB] is a list of projects that Treasury and the IRS intend to work on during the 12-month period ending June 30, 2019, and includes guidance for implementing certain measures under the new U.S. tax law (Pub. L. No. 115-97). The projects affecting exempt organizations, charitable giving, and tax-exempt bonds are listed below. 

Exempt organization guidance under the new tax law

  • Guidance on computation of unrelated business taxable income for separate trades or businesses under new section 512(a)(6) (Notice 2018-67 released on August 21, 2018)
  • Guidance on the excise tax on excess remuneration paid by “applicable tax-exempt organizations” under new section 4960
  • Regulations on the excise tax on net investment income of certain private colleges and universities under new section 4968
  • Guidance under section 274 concerning qualified transportation fringe benefits, including the application of new section 512(a)(7)
  • Regulations under section 170 providing rules governing the availability of the charitable contribution deduction when a taxpayer receives or expects to receive a state or local tax credit (proposed regulations published on August 27, 2018)
  • Guidance implementing changes made to section 529 (Notice 2018-58 released on July 30, 2018)
  • Notice on the increased contribution limit to section 529A ABLE accounts (Notice 2018-62 released August 3, 2018)
  • Regulations under sections 6011 and 6071 on filing requirements for new chapter 42 excise taxes (proposed regulations released on November 5, 2018)

Other guidance projects concerning exempt organizations

  • Final regulations on section 506 (temporary and proposed regulations published on July 12, 2016)
  • Final regulations on section 509(a)(3) supporting organizations (proposed regulations published on February 19, 2016) 
  • Guidance under section 512 regarding methods of allocating expenses relating to dual-use facilities
  • Regulations under section 529A on Qualified ABLE Programs (proposed regulations published on June 22, 2015)
  • Guidance under section 4941 regarding a private foundation's investment in a partnership in which disqualified persons are also partners  
  • Guidance regarding the excise taxes on donor advised funds and fund management (Notice 2017-73 released on December 4, 2017)
  • Guidance under section 6033 on reporting donor contributions (Rev. Proc. 2018-38 published on July 30, 2018)
  • Final regulations under section 6104(c) (proposed regulations published on March 15, 2011)
  • Final regulations designating an appropriate high-level Treasury official under section 7611 relating to church tax inquiries and examinations (proposed regulations published on August 5, 2009)

Projects listed under the heading “Tax-exempt Bonds”

  • Guidance on private activity bonds under sections 141, 142, and 147
  • Final regulations on public approval requirements for private activity bonds under section 147(f) (proposed regulations published on September 28, 2017)
  • Final regulations on arbitrage investment restrictions for tax-exempt bonds under section 148 (proposed regulations published on June 12, 2018)
  • Guidance on corrective actions for escrow investments under section 148
  • Regulations on bond reissuance under section 150
  • Guidance on current refundings of tax-advantaged bonds under section 7871(f) and disaster relief provisions
  • Guidance on tax-advantaged bond appeals procedures

Projects relating to charitable contributions

  • Final regulations under section 170 regarding charitable contributions (final regulations published on July 30, 2018)
  • Guidance under section 170(e)(3) regarding charitable contributions of inventory

Other projects

  • Projects involving employee benefits
  • Guidance under section 7701 providing criteria for treating an entity as an integral part of a state, local, or tribal government
  • Guidance under section 6050S relating to Form 1098-T, Tuition Statement (proposed regulations published on August 2, 2016) 
  • Revenue Ruling under section 102 regarding whether contributions of money received through a crowdfunding site to pay for medical expenses under section 213 are excludable from income because the contributions are gifts
  • Final regulations under section 512 explaining how to compute unrelated business taxable income of voluntary employees’ beneficiary associations described in section 501(c)(9) (proposed regulations published on February 6, 2014)
  • Final regulations on the fractions rule under section 514(c)(9)(E) (proposed regulations published on November 23, 2016)


For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Preston Quesenberry | +1 202 533 3985 |

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